The Complete UFLPA Entity List as of 2024

Enacted on December 23, 2021, the Uyghur Forced Labor Prevention Act (UFLPA) was passed with the goal of preventing U.S. importers from doing business with any companies implicated in forced labor practices in the Xinjiang-Uyghur Autonomous Region (XUAR) in China. The law, which went into effect in June of the following year, carries out this prohibition on goods imported from the XUAR in two ways. 

First, it establishes a “rebuttable presumption” that any commodities manufactured in whole or part in the XUAR were done so using forced labor, and are thus subject to 19 U.S. Code § 1307, which prohibits the importation of any products manufactured through such means. Importers may request an exception to this sweeping presumption from Customs and Border Protection, the federal agency responsible for the law’s implementation and enforcement. Businesses must clear a high bar, however, to attain those exemptions, including by showing full compliance with the UFLPA’s due diligence requirements and by providing “clear and convincing” evidence that the goods in question were not produced using forced labor. 

The CBP’s second means of enforcement is through the UFLPA Entity List. Initially published by the Department of Homeland Security on June 21, 2022, this list consists of organizations that are based in Xinjiang and mine, produce, or manufacture goods using forced labor, and those that collaborate with the Chinese government to recruit, transport, or receive Uyghurs and other persecuted groups from Xinjiang for the purposes of forced labor. In addition, the list also encompasses entities known to be participating in the country’s “poverty alleviation” and “pairing assistance” programs—government schemes widely understood to be thinly-veiled guises for systematic forced labor.  

The CBP maintains statistics on the UFLPA, and recent figures demonstrate that the agency’s enforcement has grown increasingly robust since the law’s enactment in 2022. In fiscal year 2023, CBP detained a total of $1.42 billion worth of shipments for UFLPA compliance review. Through the first five months of fiscal year 2024—the publicly available data currently runs through February—that figure has already reached nearly $1 billion, putting the agency on pace to capture over $2.3 billion worth of goods for the year. Further, February saw the highest total for a single month to date, with $300 million of imported goods subjected to the UFLPA review process. 

Since the law went into effect nearly two years ago, well over two dozen companies—including many that allegedly operated under various aliases—have been added to the DHS’s UFLPA Entity List. While these firms work in a wide range of industries that include non-ferrous metals, printing and imaging, and hair products, the list puts an especially strong emphasis on textile manufacturing businesses (CBP statistics indicate that UFLPA shipment interdictions are also heavily focused on electronics). This may be a function of the predominant sectors in the XUAR, the specific industries being targeted by the Chinese Communist Party’s (CCP) forced labor programs, or the risk assessments and intelligence-gathering efforts of the Forced Labor Enforcement Task Force (FLETF), the interagency group charged with enforcing 19 U.S. Code § 1307.

Companies Added to UFLPA Entity List on June 21, 2022

1. Baoding LYSZD Trade and Business Co., Ltd. 
2. Changji Esquel Textile Co. Ltd. (and one alias : Changji Yida Textile)
3. Hetian Haolin Hair Accessories Co. Ltd. (and two aliases: Hotan Haolin Hair Accessories; and Hollin Hair Accessories)
4. Hetian Taida Apparel Co., Ltd (and one alias: Hetian TEDA Garment)
5. Hoshine Silicon Industry (Shanshan) Co., Ltd (including one alias: Hesheng Silicon Industry (Shanshan) Co.) and subsidiaries
6. Xinjiang Daqo New Energy, Co. Ltd (including three aliases: Xinjiang Great New Energy Co., Ltd.; Xinjiang Daxin Energy Co., Ltd.; and Xinjiang Daqin Energy Co., Ltd.)
7. Xinjiang East Hope Nonferrous Metals Co. Ltd. (including one alias: Xinjiang Nonferrous)
8. Xinjiang GCL New Energy Material Technology, Co. Ltd (including one alias: Xinjiang GCL New Energy Materials Technology Co.)
9. Xinjiang Junggar Cotton and Linen Co., Ltd
10. Xinjiang Production and Construction Corps (including three aliases: XPCC; Xinjiang Corps; and Bingtuan) and its subordinate and affiliated entities
11. Aksu Huafu Textiles Co. (including two aliases: Akesu Huafu and Aksu Huafu Dyed Melange Yarn)
12. Hefei Bitland Information Technology Co., Ltd. (including three aliases: Anhui Hefei Baolongda Information Technology; Hefei Baolongda Information Technology Co., Ltd.; and Hefei Bitland Optoelectronic Technology Co., Ltd.)
13. Hefei Meiling Co. Ltd. (including one alias: Hefei Meiling Group Holdings Limited
14. KTK Group (including three aliases: Jiangsu Jinchuang Group; Jiangsu Jinchuang Holding Group; and KTK Holding
15. Lop County Hair Product Industrial Park
16. Lop County Meixin Hair Products Co., Ltd.
17. Nanjing Synergy Textiles Co., Ltd. (including two aliases: Nanjing Xinyi Cotton Textile Printing and Dyeing; and Nanjing Xinyi Cotton Textile)
18. No. 4 Vocation Skills Education Training Center (VSETC)
19. Tanyuan Technology Co. Ltd. (including five aliases: Carbon Yuan Technology; Changzhou Carbon Yuan Technology Development; Carbon Element Technology; Jiangsu Carbon Element Technology; and Tanyuan Technology Development)
20. Xinjiang Production and Construction Corps (XPCC) and its subordinate and affiliated entities
21. Yili Zhuowan Garment Manufacturing Co., Ltd.

Companies Added to UFLPA Entity List in 2023

1. Ninestar Corporation and its eight Zhuhai-based subsidiaries, which include Zhuhai Ninestar Information Technology Co. Ltd., Zhuhai Pantum Electronics Co. Ltd., Zhuhai Apex Microelectronics Co., Ltd., Geehy Semiconductor Co., Ltd., Zhuhai Pu-Tech Industrial Co., Ltd., Zhuhai G&G Digital Technology Co., Ltd., Zhuhai Seine Printing Technology Co., Ltd., and Zhuhai Ninestar Management Co., Ltd.
2. Xinjiang Zhongtai Chemical Co. Ltd.
3. Camel Group Co., Ltd.
4. Xinjiang Tianmian Foundation Textile Co., Ltd.
5. Xinjiang Tianshan Wool Textile Co. Ltd.
6. Xinjiang Zhongtai Group Co. Ltd
7. Chenguang Biotech Group Co., Ltd. and its subsidiary Chenguang Biotechnology Group Yanqi Co. Ltd.
8. Anhui Xinya New Materials Co., Ltd. (formerly known as Chaohu Youngor Color Spinning Technology Co., Ltd.; and Chaohu Xinya Color Spinning Technology Co., Ltd.)
9. COFCO Sugar Holdings Co., Ltd.
10. Sichuan Jingweida Technology Group Co., Ltd. (also known as Sichuan Mianyang Jingweida Technology Co., Ltd. and JWD Technology; and formerly known as Mianyang High-tech Zone Jingweida Technology Co., Ltd.)

The final three companies—Xinya New Materials, COFCO Sugar, and Jingweida Technology—are the most recent inclusions, having been added by the DHS in December 2023. Xinya New Materials, a textile manufacturer based in Anhui Province, was found to be collaborating with a known forced-labor program, Xinjiang Aid, to recruit individuals living in Xinjiang and transfer them to Anhui Province to work at its facilities. COFCO Sugar, a sugar and vegetable processing company headquartered in Xinjiang, participated in a PRC poverty alleviation program and traveled to XUAR villages to recruit members of persecuted ethnic minorities to work at the firm’s facilities. And Jingweida Technology, an electronics manufacturer that produces network transformers and other magnetic devices, cooperated with the local government in Awati County to transfer members of persecuted groups out of Xinjiang to work in its factories in Sichuan Province. 

Sanctions with Teeth and Political Will 

As the aforementioned statistics indicate, the level and scope of UFLPA enforcement has been steadily increasing in 2024. Frustrations voiced by some U.S. companies notwithstanding, there is a strong and unusually bipartisan political will to continue holding the PRC accountable for its systematic human rights abuses. Over the course of 2023, multiple congressional groups, including the bill’s original sponsors and the House Select Committee on the CCP, submitted policy recommendations aimed at expanding the UFLPA and its enforcement mechanisms. Social justice and human rights organizations, meanwhile, continue to agitate for more aggressive measures to punish China’s inhumane practices and interdict goods implicated in the CCP’s forced-labor programs from entering the U.S. supply chains. 

This is, in short, a regulation that is not going to be diminished or dismissed anytime soon, largely because the geopolitical justification for the law continues to be a grave and urgent issue. (Forced labor experts have suggested that as many as 55,000 companies are operating in some capacity in the Uyghur Region, with at least 150 knowingly participating in state-sponsored labor transfer programs.) And as the DHS press release announcing the most recent additions to the UFLPA Entity List noted, the agency puts a high prioritization on “combatting the introduction of forced labor into U.S. supply chains,” and FLETF “will continue to consider future designations to the UFLPA Entity List.”